DOJ IG - Audit of The FBI's Controls Over Weapons, Munitions, and Explosives

Office of the Inspector General
U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE
Audit of the Federal Bureau of

Investigation’s Controls over
Weapons, Munitions, and
Explosives
Audit Division 20-041 March 2020

Executive Summary
Audit of the Federal Bureau of Investigation’s Controls over Weapons,
Munitions, and Explosives
Objectives Audit Results

The objectives of this audit were to evaluate: (1) the As of August 2019, the FBI reported 57,812 firearms in
Federal Bureau of Investigation’s (FBI) controls over its inventory. The FBI also maintains large quantities of
weapons, munitions, and explosives; (2) the FBI’s ammunition for duty use, training, and periodic firearms
compliance with policies governing weapons, munitions, qualifications. In addition, the FBI’s Tactical Section
and explosives; and (3) the accuracy of the FBI’s and Special Weapons and Tactics teams maintain a
weapons, munitions, and explosives inventories. variety of specialty weapons and less lethal munitions,
and diversionary devices. The FBI also employs Special
The audit covers the FBI’s weapons, munitions, and
Agent Bomb Technicians who maintain inventories of
explosives inventories from fiscal year (FY) 2016
explosives.
through November 2019. To accomplish our objectives,
we interviewed FBI personnel; evaluated FBI policies Controls over Firearms – We found that the FBI has
governing weapons, munitions, and explosives; strong physical controls over its unassigned firearms,
analyzed select data fields in the firearms inventory and Special Agents are personally responsible for
database; and reviewed firearm and explosives properly safeguarding assigned firearms. The FBI
purchases. We also reviewed documentation related to tracks its firearms using the Asset Management System
firearms that were reported as lost or stolen during the (AMS), its automated property management system.
scope of our audit to determine whether the FBI took During our physical inventory we were able to locate all
appropriate action. Finally, we assessed compliance firearms selected for our sample. However, we
with FBI policy and conducted physical inventories at identified over 360 firearms without a designated
15 FBI sites. property custodian in AMS, which is against FBI policy.
We also selected a sample of firearms during our site
Results in Brief visits and traced all but two of them back to AMS. The
We found that firearms in our sample were recorded in FBI could not explain the origins of these two firearms,
the FBI’s inventory system and in the custody of the or how they came to be in FBI custody.
assigned Special Agent or stored in a secure area as We also determined that our sample of firearms
required. However, we identified non-compliance issues purchased during a 2 month period were properly
related to the FBI’s ammunition inventories. We also entered into AMS in a timely manner. Additionally, we
identified concerns related to tracking FBI ammunition, evaluated the FBI’s controls over firearms approved for
less lethal munitions, diversionary devices, and disposal and identified deficiencies related to the
explosives; and firearms slated for disposal. Finally, we accuracy of AMS records for destroyed firearms.
identified areas where FBI policies should be established
or revised to improve the safeguarding of its Lost and Stolen Firearms – We noted that between
ammunition, less lethal munitions, diversionary devices, September 2016 and July 2019, 38 FBI Special Agents
and explosives. were disciplined for the loss or theft of 45 FBI-issued
firearms. The FBI suspended 37 and dismissed 1 of the
Recommendations Special Agents held responsible for the loss or theft. Of
the 45 lost or stolen firearms, 24 have been recovered,
Our report contains 13 recommendations to improve
1 of which was used in a crime. We also found that the
the FBI’s controls over its weapons, ammunition, less
FBI did not maintain complete documentation for 8 of
lethal munitions, diversionary devices, and explosives.
the 45 lost or stolen firearms, including its make,
We requested a response to the draft report from the
model, or serial number; and a stolen firearm that was
FBI, which can be found in Appendix 2. Our analysis of
subsequently recovered more than 1 year ago was still
that response is included in Appendix 3.
marked as lost or stolen in AMS.
i
Executive Summary
Audit of the Federal Bureau of Investigation’s Controls over Weapons,
Munitions, and Explosives
Controls over Ammunition – The FBI maintained duty Controls over Firearm and Ammunition Evidence –
ammunition at 14 of the 15 sites we reviewed. We We determined that the FBI had strong physical
found that the FBI stored its ammunition in secured controls over firearm and ammunition evidence and
areas with access limited to FBI personnel. However, access to the Evidence Control Rooms was limited to
we identified weaknesses in the FBI’s ammunition designated personnel and required a keycard,
tracking and physical inventory policies that increase combination, and alarm code. The FBI tracks its
the risk of ammunition being lost or stolen without firearms and ammunition evidence using SENTINEL.
detection. As a result, we found that 6 of the FBI sites During our physical inventory of firearm and
included in our audit were not tracking over 1.2 million ammunition evidence, we located all items selected for
rounds of ammunition, and another 7 sites were not our sample and traced a sample of firearm and
adequately tracking ammunition. ammunition evidence back to SENTINEL.
Controls over Less Lethal Munitions and However, we identified concerns related to firearm
Diversionary Devices – The FBI maintained less lethal evidence sent to the Firearms/Toolmarks Unit (FTU) for
munitions and diversionary devices at 6 of the 15 sites destruction. Specifically, the current process of
we reviewed. Despite the lack of a policy establishing shipping firearm evidence to the FTU for destruction
proper storage requirements, we found that the FBI creates a risk that firearms could be lost in transit
stored its less lethal munitions and diversionary devices without detection; and firearms are being marked as
in a secure area with limited access. However, we disposed in SENTINEL before the firearms are actually
identified weaknesses in the FBI’s tracking and physical destroyed.
inventory policies for less lethal munitions and
diversionary devices that increases the risk of their
being lost or stolen without detection. As a result, we
found that one FBI site was not tracking less lethal
munitions and diversionary devices and that the
remaining five sites we visited were not adequately
tracking them.
Controls over Explosives – The FBI maintained

explosives at 8 of the 15 sites we reviewed. We found
that the FBI properly stored its explosives in accordance
with FBI policy. However, we found two explosive
magazines used to store FBI explosives were not owned
by the FBI, but rather by state and local law
enforcement agencies. As a result, the bomb
technicians of these other agencies had emergency
access to the FBI’s explosives. Additionally, we
identified weaknesses in the FBI’s explosives tracking
and physical inventory policies that increase the risk of
explosives being lost or stolen without detection. As a
result, we found that only two of the eight sites
included in our audit were adequately tracking their
explosives inventories.
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AUDIT OF THE FEDERAL BUREAU OF INVESTIGATION’S
CONTROLS OVER WEAPONS, MUNITIONS, AND EXPLOSIVES
TABLE OF CONTENTS
INTRODUCTION .................................................................................... 1
OIG Audit Approach ....................................................................... 1
AUDIT RESULTS.................................................................................... 3
Controls over Firearms ................................................................... 3
Physical Security of Firearms ................................................... 3
Accuracy of the FBI’s Asset Management System .......................... 3
Firearm Purchases ................................................................ 4
Firearm Disposal .................................................................. 5
Lost and Stolen Firearms ........................................................ 5
Controls over Ammunition ............................................................... 8
Physical Security of Ammunition ............................................... 8
Ammunition Tracking ............................................................. 9
Results of the Ammunition Inventory ....................................... 10
Controls over Less Lethal Munitions and Diversionary Devices ................ 10
Physical Security of Less Lethal Munitions and Diversionary Devices .. 11
Tracking Less Lethal Munitions and Diversionary Devices .............. 11
Results of the Less Lethal Munitions and Diversionary Devices

Inventory ................................................................. 12
Controls over Explosives ............................................................... 12
Physical Security of Explosives ............................................... 13
Tracking Explosives ............................................................. 13
Results of the Explosives Inventory ......................................... 14

Explosives Purchases ........................................................... 15
Controls over Firearm and Ammunition Evidence................................. 15
Physical Security of Firearm and Ammunition Evidence ................. 15
Accuracy of the FBI’s Firearm and Ammunition Evidence Inventory . 15
Disposal of Firearm Evidence ................................................. 16
CONCLUSION AND RECOMMENDATIONS ................................................... 18
APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY.............................. 20
APPENDIX 2: THE FBI’S RESPONSE TO THE DRAFT AUDIT REPORT ................. 24
APPENDIX 3: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY

OF ACTIONS NECESSARY TO CLOSE THE REPORT ............................... 30
AUDIT OF THE FEDERAL BUREAU OF INVESTIGATION’S
CONTROLS OVER WEAPONS, MUNITIONS, AND EXPLOSIVES
INTRODUCTION
The Federal Bureau of Investigation (FBI) currently employs over 13,000

Special Agents located throughout the world, including over 400 domestic field
offices and resident agencies, and 91 offices in 75 foreign countries. In support of
its operations, the FBI maintains weapons, munitions, and explosives, including
firearms, ammunition, less lethal munitions, diversionary devices, and explosives.
FBI Special Agents are required to carry a primary-duty handgun, and may
be issued supplemental handguns, rifles, and shotguns. FBI employees also have
the option of using authorized personally-owned firearms for duty use, and carrying
oleoresin capsicum (OC) spray. As of August 2019, the FBI reported 57,812 firearms
in its inventory, which are tracked through the FBI’s automated property management
database, the Asset Management System (AMS). The FBI also maintains large
quantities of ammunition for duty use, training, and periodic firearms qualifications.
In addition, the FBI’s Tactical Section and Special Weapons and Tactics
(SWAT) teams maintain a variety of specialty weapons and munitions, including
fully automatic machine guns; projectile launching devices and less lethal
projectiles; smoke grenades; and Noise Flash Diversionary Devices, commonly
referred to as flash bang grenades.
As a result of its criminal enforcement activity, FBI personnel may seize

firearms and ammunition as evidence. Firearms and ammunition evidence must be
tracked using SENTINEL, the FBI’s central recordkeeping and case management
system. All firearms and ammunition evidence must be stored in a secure Evidence
Control Room. Additionally, FBI policy requires that firearms and ammunition
evidence be stored separately, with the firearms packaging identifying the caliber,
make, model, and serial number.
OIG Audit Approach
Our objectives were to evaluate: (1) the FBI’s controls over weapons,
munitions, and explosives; (2) the FBI’s compliance with policies governing
weapons, munitions, and explosives; and (3) the accuracy of the FBI’s weapons,
munitions, and explosives inventories. The scope of our audit generally covers the
FBI’s inventories of firearms, ammunition, less lethal munitions, diversionary
devices, and explosives, including firearms and ammunition seized as evidence,
firearm and explosives purchases, and FBI-issued firearms reported lost or stolen,
from September 2015 through November 2019.
To accomplish our objectives, we interviewed FBI personnel, including

officials from the Finance, Inspection, Training, and Laboratory Divisions, as well as
the Critical Incident Response Group. In addition, we evaluated the FBI’s policies
governing weapons, munitions, and explosives, and reviewed documentation
related to firearms and explosives purchases to ensure that acquisitions were
1
properly recorded.1 We also reviewed documentation related to firearms that were
reported as lost or stolen during the scope of our audit to determine whether the
FBI took appropriate action. Finally, we conducted site work at 15 FBI sites, as
shown in Table 1.2
Table 1
FBI Offices Selected for Audit
FBI Office FBI Firearms Firearms Evidence
Denver Division
Denver Field Office 374 400
Loveland Resident Agency 27 0
Chicago Division
Chicago Field Office 1,079 1,439
Milwaukee Division
Milwaukee Field Office 289 163
Madison Resident Agency 32 0
Sacramento Division
Sacramento Field Office 333 584
Stockton Resident Agency 40 0
Boston Division
Boston Field Office 451 351
Providence Resident Agency 75 0
New Haven Division
New Haven Field Office 227 311
Training Division
Firearms Training Unit 1,322
Defensive Systems Unit 9,212
Laboratory Division
Firearms/Toolmarks Unit 7,863
Critical Incident Response Group
Tactical Section 1,847
Hazardous Devices School 31
Source: The FBI’s AMS; the FBI’s SENTINEL
The purpose of our site work was to assess the FBI’s compliance with policies
regarding its weapons, munitions, and explosives, as well as the effectiveness of
those policies. As applicable, we also conducted a physical inventory of a sample of
firearms, ammunition, less lethal munitions, diversionary devices, and explosives at
the sites we visited. In addition, we assessed the FBI’s compliance with policies
regarding firearms and ammunition seized as evidence. Finally, we conducted a
physical inventory of a sample of firearm and ammunition evidence. Appendix 1
contains a more detailed description of our audit objectives, scope, and methodology.
1 See Appendix 1 for a list of FBI policies we reviewed.

2 We selected a broad range of FBI offices and functions for our site work, including large
division offices; smaller Resident Agencies; the FBI’s Training Academy; the Critical Incident Response
Group’s Tactical Section, and the Hazardous Devices School.
2
AUDIT RESULTS
We found that the FBI has strong physical controls over its unassigned
firearms and that Special Agents are personally responsible for properly
safeguarding assigned firearms. However, we identified over 360 firearm inventory
records that did not include a designated property custodian as required by FBI
policy. We also identified weaknesses in the FBI’s controls over tracking its
ammunition, less lethal munitions, diversionary devices, and explosives, which, in
our judgement, create a risk that these sensitive items may be lost, misplaced, or
stolen without detection. Specifically, we found that the FBI’s ammunition, less
lethal munitions, diversionary devices, and explosives tracking and inventory
requirements were either not specific, or non-existent; as a result, at 14 of the
sites included in our audit, these items were not tracked or were not adequately
tracked. In addition, at two sites the FBI is storing its explosives in a magazine
owned by state and local law enforcement agencies who have emergency access.
Finally, we identified concerns with the FBI’s firearm evidence disposal process,
which increases the risk that firearms sent for destruction may be lost during
shipping.
Controls over Firearms
The FBI tracks its firearms inventory using an automated property

management database known as AMS. The FBI also conducts an annual physical
inventory of all of its firearms. During our site visits, we performed a physical
inventory and were able to locate all of the weapons selected for our sample. We
were also able to trace another sample of weapons back to AMS, although we noted
some data errors in AMS. Additionally, we identified 369 firearms for which the
AMS records did not include a designated property custodian as required by FBI
policy. Finally, from September 2015 through July 2019, the FBI reported 45 of its
firearms as lost or stolen.
Physical Security of Firearms
We found that the FBI had strong physical controls over unassigned firearms.
Special Agents are personally responsible for properly safeguarding their assigned
firearms at all times. Additionally, FBI offices have designated staff, Primary
Firearms Instructors, who are responsible for all firearms that are not issued to an
employee. When assigned firearms are not in the personal custody of Special
Agents they must be placed in a secure, locked storage area to prevent
unauthorized handling. At the 15 FBI sites we visited, we found that all of the
firearms in our sample were either in the custody of the assigned Special Agent or
stored in a secure area.
Accuracy of the FBI’s Asset Management System
As of August 2019, the FBI reported 57,812 firearms in its inventory. We

selected a sample of 422 firearms from AMS to ensure that they were physically
accounted for and accurately tracked in the system. We selected an additional
3
185 firearms while on site to ensure that the field sites’ AMS records were complete
and accurate. During our physical inventory, we located all 422 firearms in our
sample and traced 183 of the additional 185 firearms back to AMS. We were
unable to trace two firearms back to AMS, both of which were located in a gun safe
in the Madison Resident Agency. The Firearms Instructor in Madison explained that
the origins of the firearms were unknown. As a result, the FBI needs to determine
the rightful owner of these firearms and take appropriate action. Therefore, we
recommend that the FBI ensure all firearms in its custody are properly entered into
the appropriate property management system. All FBI-issued firearms should be
entered into AMS and all firearm evidence should be entered into SENTINEL.
During our physical inventory, we also identified data errors in AMS for 20 of
the firearms included in our sample, related to the make, model, serial number,
location, or assigned user. An FBI official explained that the errors may be
attributed to invalid or corrupted data fields that occurred during its migration to
AMS from the FBI’s prior property management system. While these inaccuracies
did not significantly impact our ability to locate the firearms and the FBI either
corrected or submitted a service request to correct the errors, it is important that
the FBI maintains current and accurate information in AMS.
Additionally, we identified 32 AMS records for the firearms in our sample that
did not include an assigned property custodian. The FBI’s Personal Property
Management Policy Guide requires all accountable assets in AMS be assigned to a
property custodian. This designation is particularly important because property
custodians are responsible for the stewardship of all assets assigned to them. As a
result, we expanded our analysis concerning the assignment of property custodians
to include all 23,201 firearms listed in AMS for the 15 sites included in our audit.
Based on our expanded analysis, we found that a total of 369 firearms did not have
an assigned property custodian in AMS. Without a designated property custodian,
the FBI cannot be assured that all of its firearms are properly safeguarded.
Therefore, we recommend that the FBI ensure all firearms in its inventory have a
designated property custodian, in accordance with policy.
Firearm Purchases
The FBI’s Defensive Systems Unit (DSU) is responsible for purchasing,

receiving, and test-firing all new firearms. According to a DSU official, once DSU
receives a shipment of new firearms, the contents of the shipping container are
inventoried against the receiving documents. Once all firearms are accounted for,
the receiving documents are signed and dated, approved by a DSU program
manager, and forwarded to an Inventory Management Specialist. The Inventory
Management Specialist then submits a service request in AMS to have the firearm
entered into the inventory, including all pertinent information such as the firearm
manufacturer, model, and serial number. Once the record is complete, the firearm
becomes operational and can be issued to a user. We reviewed a sample of 226
purchased firearms that were received in July and August 2019. Based on our
review, we did not identify any concerns related to the FBI’s firearm purchases.
Additionally, we found that all 226 firearms were correctly entered into AMS.
4
Firearm Disposal
We identified concerns related to the record keeping of disposed FBI-issued

firearms. The FBI’s DSU is responsible for destruction of FBI-issued firearms. A
DSU official explained that only the DSU Chief, or its designee, can determine
whether FBI-issued firearms are eligible for destruction, after which the Asset
Management Unit provides the authority for DSU to destroy weapons. For each
firearm approved by DSU for destruction, DSU prepares a Form FD-519,
Requirements and Certification for Cannibalization and Destruction of Equipment;
photographs the firearm’s serial number; and places the firearm into a cardboard
box. Once the box contains 50 firearms, it is inventoried and sealed, and the list of
contents is attached to the outside of the box. The box is then stored in a secure
vault and wrapped with other sealed disposal boxes prior to being escorted to the
destruction facility. The disposal process is witnessed by two FBI employees from
two vantage points and the destruction is certified on the Form FD-519. An
Inventory Management Specialist uses the serial number photos to verify the
disposal status of firearm records in AMS and submits a service request in AMS that
must be approved by the Asset Management Unit before the inventory record is
updated. We examined the physical security of the disposal boxes and found that
they were properly stored in a secure area with access limited to designated
officials.
However, we found two destroyed FBI prop guns that were still listed in the
FBI’s active inventory. The property numbers for both prop guns were listed on the
inventory sheet with serial numbers of 48 other firearms awaiting disposal.
According to a DSU official, prop guns are non-functioning items used for training.
They are not actual firearms and do not have serial numbers. However, they are
assigned an FBI property number and entered into AMS. The DSU official explained
that since these prop guns did not have serial numbers, the disposal information
was not recorded in AMS. Because these were not actual firearms, we are not
making a recommendation related to this issue.
Lost and Stolen Firearms
Between September 2015 and July 2019, 38 FBI Special Agents reported
45 assigned FBI firearms as lost or stolen. We noted that 24 of the 45 lost or
stolen firearms have been recovered, 1 of which was used in the commission of an
attempted robbery while outside of the FBI’s custody.
The details related to the 45 lost and stolen firearms included in our analysis
are shown in Table 2.
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Table 2
Lost and Stolen FBI Firearms
Type
of Firearm Involved Disciplinar
Loss Type of Firearm Recovered in a Crime Synopsis y Action
Stolen Springfield pistol No Unknown Stolen from 3-day
Stolen Colt carbine No Unknown government vehicle suspension
Inadequately 3-day
Lost Glock pistol No Unknown
safeguarded suspension
Stolen Springfield pistol No Unknown Inadequately 5-day
Stolen Glock pistol No Unknown safeguarded suspension
3-day
Stolen Glock pistol No Unknown Stolen from rental car
suspension
Stolen H&K submachine gun No Unknown Stolen from 3-day
Stolen Remington shotgun No Unknown government vehicle suspension
Left in public 3-day
Lost Unknown Yes Unknown
restroom suspension
3-day
Lost Glock pistol Yes Unknown Left on truck bumper
suspension
Stolen from 3-day
Stolen Glock pistol No Unknown
government vehicle suspension
Failed to record
3-day
Lost Glock training pistol Yes No issuance of training
suspension
firearm in AMS
Stolen Rock River carbine No Unknown Stolen from 5-day
Stolen Glock pistol No Unknown government vehicle suspension
Stolen Rock River carbine Yes Stolen from 3-day
Yes, 1 of 2
Stolen H&K submachine gun Yes government vehicle suspension
Stolen from 7-day
3-day
Lost Glock pistol Yes Unknown Left in public area
suspension
Misplaced in 3-day
Lost Glock pistol Yes Unknown
residence suspension
Left in public 3-day
Lost Unknown Yes Unknown
restroom suspension
45-day
Stolen Glock pistol No Unknown Stolen from residence
suspension
Inadequately 3-day
Stolen H&K submachine gun No Unknown
5-day
Lost Remington shotgun Yes Unknown Left on trunk of car
suspension
Inadequately 3-day
Lost Handgun Yes Unknown
3-day
Lost Unknown Yes Unknown Left in hotel room
suspension
Misplaced in 3-day
Misplaced by Special 3-day
Lost Glock training pistol No Unknown
Agent suspension
3-day
Lost Glock pistol Yes Unknown Left in hotel restroom
suspension
6
Assigned Special
Sig Sauer training Agent could not 3-day
Lost No Unknown
pistol account for firearm suspension
during inventory
Lost during training 3-day
Lost Glock pistol No Unknown
exercise suspension
3-day
Stolen Glock pistol Yes Unknown Stolen by daughter
suspension
Misplaced in 5-day
Lost Springfield pistol Yes Unknown
Stolen from personal 3-day
vehicle suspension
Misplaced at prison 7-day
facility suspension
Stolen from 3-day
Stolen Colt carbine Yes Unknown
Stolen from hotel
Stolen Glock pistol Yes Unknown Dismissal
room
5-day
Stolen Unknown Yes Unknown Stolen from airport
suspension
3-day
Stolen Glock pistol Yes Unknown Stolen from vehicle
suspension
60-day
Stolen Glock pistol No Unknown Stolen from vehicle
suspension
Stolen Colt carbine No Unknown
Inadequately 3-day
Stolen Glock pistol Yes Unknown
Inadequately 3-day
Stolen H&K submachine gun No Unknown
Stolen from 3-day
Stolen H&K submachine gun Yes Unknown
Left in restaurant 3-day
bathroom suspension
Source: The FBI’s Office of Professional Responsibility
We reviewed the FBI’s records to determine whether it took disciplinary

action in response to these lost or stolen firearms incidents. We found that in 37 of
the 38 incidents, the Special Agent responsible for the loss or theft was suspended
between 3 and 60 days; the most common suspension was 3 days. For the
remaining incident, the circumstances of the theft were serious enough to warrant
dismissal of the Special Agent responsible.
To ensure the accuracy of the FBI’s tracking information, we reviewed AMS

records for the 21 lost or stolen firearms that remain missing to confirm that none
of them appear in the FBI’s active inventory record. Similarly, we attempted to
confirm that the inventory records for all 24 recovered firearms have been
appropriately updated in AMS. However, we found that the FBI did not maintain
complete documentation for 8 of the 45 lost or stolen firearms, including its make,
model, or serial number. As a result, we were unable to determine if the AMS
records were accurate. When a firearm is lost or stolen, FBI policy requires Primary
Firearm Instructors to prepare an Electronic Communication that includes all of the
details about the incident, including the serial number of the weapon. The Primary
Firearm Instructor must also prepare a Form FD-500, Report of Lost or Stolen
7
Property, that includes the serial number and description of the firearms. The fact
that the FBI was unable to provide this information indicates that the policy is not
being properly followed. As a result, we recommend that the FBI ensures that
complete documentation of lost and stolen FBI firearms is maintained, including all
pertinent information such as the firearm make, model, and serial number.
Additionally, a stolen firearm that was subsequently recovered more than 1 year
ago was still marked as lost or stolen in AMS. In our judgment, AMS should always
maintain current and accurate inventory data for all firearms. Therefore, we
recommend that the FBI ensure that the status of all lost or stolen firearms that are
subsequently recovered is accurately reflected in AMS.
Finally, we assessed the rate of loss of FBI firearms over a 47-month period
from September 2015 through July 2019 to determine how it compared to the loss
rate identified in our prior 2002 and 2007 OIG audits.3 We found that the FBI
experienced 0.96 losses or thefts per month over the 47-month period from 2015
to 2019, which is a significant decrease over the monthly loss rates of 7.6 and 3.2
losses or thefts per month identified in the 2002 and 2007 OIG audits, respectively.
While the FBI has substantially reduced the rate of lost and stolen firearms since
our prior audits, it must continuously work toward reducing this rate.
Controls over Ammunition
The FBI maintained duty ammunition at 14 of the 15 sites we reviewed. We

found that the FBI had strong physical controls to ensure that ammunition is stored
in secure locations at all 14 sites we visited. We also determined that 6 of 14 sites
were not tracking over 1.2 million rounds of ammunition. Additionally, while the
eight remaining sites had a method for tracking ammunition, only one site was
adequately tracking ammunition. In our judgment, the issues we identified related
to tracking ammunition primarily resulted from the FBI’s inadequate ammunition
tracking policy. We also identified areas where the FBI ammunition policy could be
improved.
Physical Security of Ammunition
FBI policy requires that ammunition be stored in a secure area with strictly
controlled access. At all 14 sites that had ammunition inventories, we found that
the ammunition was kept in a secure storage area. However, at 1 of the 14 sites a
local task force officer had access to the FBI ammunition storage area. Subsequent
to our site visit, this office moved its ammunition to a new location and now limits
access to only designated FBI personnel. As a result, we are not making a
recommendation related to this issue.
3 Audit Report 02-27, The Federal Bureau of Investigation’s Control over Weapons and Laptop
Computers, August 2002; and Audit Report 07-18, The Federal Bureau of Investigation’s Control over
Weapons and Laptop Computers Follow-Up Audit, February 2007.
8
Ammunition Tracking
Strong controls over ammunition require an inventory management system

that maintains accurate, current, and historical data—to include increases and
decreases in inventory and the reason for the changes in quantity over time. While
FBI policy states that Primary Firearms Instructors should account for all
ammunition usage, the policy does not specify how ammunition should be tracked.
We believe that this is a control weakness that increases the risk of ammunition
being lost, misplaced, or stolen without detection. In our judgment, handwritten
logs should be maintained in the ammunition storage area to facilitate consistent
use and avoid the necessity for computer access on-site. Handwritten logs also
ensure that the tracking method includes an audit trail of recorded transactions,
which is a control that can be circumvented using an electronic inventory log that
allows the user to overwrite the data. Therefore, we recommend that the FBI
amend its policy for tracking ammunition to require that all rounds of each type of
ammunition be tracked using handwritten logs that detail the date, caliber, quantity
in or out, purpose of the ammunition transaction, and remaining balance; and that
the FBI require all ammunition tracking logs to be retained for at least 3 years.
We found that 6 of the 14 FBI sites included in our audit were not tracking
over 1.2 million rounds of ammunition. The remaining eight sites were using
various methods to track ammunition, including logging ammunition transactions or
periodically updating the balance of ammunition on hand. However, the Firearms
Training Unit was the only site that adequately tracked all ammunition transactions
in and out of the storage area and maintained a running balance of ammunition on
hand, which we view as a best practice that the FBI should implement at all offices.
Table 3 outlines ammunition tracking methods and the related deficiencies we
identified at the 14 sites included in our analysis.
Table 3
Ammunition Tracking Deficiencies
Site Tracking Methods Tracking Deficiencies
Handwritten log with Office only recently started tracking
Denver Field Office transactions and running ammunition; not all ammunition was
balances being tracked
Loveland Resident
None Ammunition was not tracked
Agency
Transactions were not being recorded,
Electronic log showing
Boston Field Office no historical data, and ending
inventory totals
balances were not updated regularly
Providence Resident
Agency
Handwritten log with
Two separate tracking methods that
Chicago Field Office transactions and electronic log
were not reconciled regularly
with running balances
Milwaukee Field Office Transactions were not being recorded
inventory totals
Handwritten log with Office only recently started tracking
Madison Resident
transactions and electronic log ammunition; two separate tracking
Agency
with running balances methods
9
Sacramento Field Office None Ammunition was not tracked
Stockton Resident
Agency
New Haven Field Office None Ammunition was not tracked
CIRG – Tactical Section transactions and electronic log No historical running balances
Defensive Systems Unit None Ammunition was not tracked
Hazardous Devices Electronic log showing Transactions were not being recorded
School inventory totals and no historical data
Firearms Training Unit transactions and electronic log None
Source: The FBI and OIG
Results of the Ammunition Inventory
In order to assess the accuracy of the FBI’s ammunition inventories, we

conducted a physical inventory of ammunition at the 14 sites we visited that
maintained ammunition. As stated previously, 6 of the 14 sites were not tracking
ammunition; as a result, we could not assess the accuracy of their ammunition
inventories. For the remaining eight sites that had some type of ammunition
tracking system, we identified discrepancies between the quantities of ammunition
on hand and the recorded inventory balance at six sites. In total for the six sites,
the balances recorded in the ammunition inventory records were understated by
over 174,000 rounds, meaning that the FBI had more ammunition on hand than
what was documented. In our judgment, the discrepancies we identified are a
direct result of the FBI’s insufficient ammunition tracking and inventory policies.
We also found that the FBI’s policy for conducting periodic physical
inventories of its ammunition needs improvement. While the FBI requires its offices
to conduct annual physical inventories of its ammunition, this function is primarily
performed to allow the Finance Division to account for all FBI assets. In our
judgment, a physical ammunition inventory should also ensure that the running
balances on ammunition tracking logs are accurate by reconciling the ammunition
on hand to the logged inventory balance. However, this is not required by current
FBI policy. When implemented effectively, this physical inventory practice should
detect if ammunition goes missing. We observed this form of physical ammunition
inventory being conducted at the FBI’s Firearms Training Unit and its Tactical
Section, which we view as a best practice that the FBI should implement agency-
wide. Therefore, we recommend that the FBI revise its current policy to require its
offices to conduct a complete inventory of all ammunition on hand on an annual
basis to ensure all recorded ammunition inventory balances are accurate, and to
retain those records for at least 3 years.
Controls over Less Lethal Munitions and Diversionary Devices
The FBI maintained less lethal munitions and diversionary devices, including
pepper spray, handheld and projectile chemical agents, breaching munitions,
smoke grenades, and flash bang grenades, at 6 of the 15 sites we reviewed. We
10
found that the FBI has strong physical controls over its less lethal munitions and
diversionary devices at these six sites. However, we identified deficiencies related
to the FBI’s tracking of its less lethal munitions and diversionary devices. We also
found that the FBI was not conducting annual physical inventories of its less lethal
munitions and diversionary devices.
Physical Security of Less Lethal Munitions and Diversionary Devices
We found that the FBI has strong physical controls over its less lethal
munitions and diversionary devices. While the FBI does not have policy outlining
storage requirements for less lethal munitions and diversionary devices, we
observed that less lethal munitions and diversionary devices at all six sites were
kept in a secure storage area. We also found that all six sites limited access to the
secure storage areas to designated personnel. However, without established
storage requirements, there is a risk that less lethal munitions and diversionary
devices may not be properly safeguarded from loss or theft at all FBI locations. In
our judgment, the FBI should formalize its current storage practices in policy.
Therefore, we recommend that the FBI establish policy requiring that less lethal
munitions and diversionary devices must be stored in a secure area, with access
limited to designated personnel.
Tracking Less Lethal Munitions and Diversionary Devices
Strong controls over less lethal munitions and diversionary devices require an
inventory management system that maintains accurate, current, and historical
data—to include increases and decreases in inventory and the reason for the
changes in quantity over time. However, the FBI’s policy merely suggests that
Primary Firearms Instructors create an inventory system for all expendable
commodities, and is largely silent with regard to tracking less lethal munitions and
diversionary devices. In our judgment, this is a control weakness that increases
the risk of less lethal munitions and diversionary devices being lost, misplaced, or
stolen without detection. Therefore, we recommend that the FBI establish policy
for tracking less lethal munitions and diversionary devices that requires all
quantities of each type of less lethal munition and diversionary device be tracked
using handwritten logs that detail the date, quantity in or out, purpose of the
transaction, and remaining balance; and that the FBI require all less lethal munition
and diversionary device tracking logs to be retained for at least 3 years.
We found that one of the six FBI sites included in our audit was not tracking
less lethal munitions and diversionary devices. The remaining five sites were using
various methods to track these items, only some of which adequately logged
transactions or kept a running balance of less lethal munitions and diversionary
devices on hand. While none of these five sites were adequately tracking all less
lethal munitions and diversionary devices, the Denver and Chicago Field Offices
tracked usage of flash bang grenades and maintained a record showing which
Special Agents had these munitions in their custody, which we view as a best
practice that the FBI should implement at all offices. Table 4 outlines the various
methods used by the FBI offices we visited to track less lethal munitions and
11
diversionary devices, as well as the deficiencies we found with those tracking
methods.
Table 4
Less Lethal Munition and Diversionary Device Tracking Deficiencies
Electronic log showing Not all transactions were being
Denver Field Office
inventory totals recorded (only flash bang grenades)
Chicago Field Office
inventory totals recorded (only flash bang grenades)
Electronic log showing Transactions were not being recorded
Milwaukee Field Office
inventory totals and no historical data
Madison Resident Electronic log showing Transactions were not being recorded
Agency inventory totals and no historical data
New Haven Field Office None Less lethal munitions were not tracked
CIRG – Tactical Section
Results of the Less Lethal Munitions and Diversionary Devices Inventory
We conducted a physical inventory of less lethal munitions and diversionary

devices at the six sites that maintained these inventories. We identified
discrepancies between the quantities of less lethal munitions and diversionary
devices on hand and the recorded inventory balance at three of the five sites that
tracked these items. In total, these sites overstated their recorded inventories of
less lethal munitions and diversionary devices on hand by 87 items. In our
judgment, the discrepancies we identified are primarily a result of the FBI’s
deficient less lethal munition and diversionary device tracking and inventory
policies.
In addition, we found that the FBI does not require periodic physical
inventories of its less lethal munitions and diversionary devices. In our judgment, a
physical inventory of all less lethal munitions and diversionary devices should be
conducted regularly to ensure all items are properly accounted for on the inventory
tracking documents. Consequently, we recommend that the FBI require its offices
to conduct a complete physical inventory of all less lethal munitions and
diversionary devices on an annual basis and retain those records for at least
3 years.
Controls over Explosives
The FBI maintained explosives at 8 of the 15 sites we reviewed. We found

that the FBI has strong physical controls over its explosives at all eight locations we
visited. However, we identified deficiencies related to the FBI’s tracking of its
explosives. We also found that the FBI was not conducting annual physical
inventories of explosives.
12
Physical Security of Explosives
We found that the FBI has strong physical controls over its explosives. At
each of the eight sites we visited with an explosives inventory, explosives were
stored in a secure area with access limited to designated bomb technicians.
However, we noted that two of the explosive magazines used to store FBI
explosives were not owned by the FBI, but rather by state or local law enforcement
agencies. As a result, the bomb technicians of these state and local law
enforcement agencies had access to the FBI’s explosives inventories. It should be
noted that these agencies did not store explosives in the same magazine as the
FBI, and the access they were granted was for emergency purposes only.
According to an FBI Special Agent Bomb Technician (SABT), it is cost-prohibitive for
the FBI to maintain its own explosive magazines in field offices with a small number
of SABTs, which necessitates these types of explosives storage arrangements with
other law enforcement agencies. In our judgment, the risk posed by granting
non-FBI employees access to the FBI’s explosives can be mitigated by
implementing our recommendations related to tracking explosives and conducting
periodic physical explosives inventories, which are discussed in the following
sections. Consequently, we are not making a recommendation related to this issue.
Tracking Explosives
Strong controls over explosives require an inventory management system

that maintains accurate, current, and historical data—to include increases and
decreases in inventory and the reason for the changes in quantity over time. While
FBI policy requires SABTs to maintain strict accountability and security for all
explosives, the policy does not specify how SABTs should account for and track
their explosives inventories. As a result, various methods were used to track
explosives at the eight sites we visited that maintained explosives. We found that
only two sites, the FBI’s Hazardous Devices School and the Sacramento Field Office,
were effectively tracking explosive materials. Both sites maintained hand-written
logs for each type of explosive material stored in its magazines that tracked all
movement of explosives in and out of the storage area, and the remaining balance
on hand. In our judgment, this is a best practice that the FBI should implement
agency-wide, to ensure explosives are not lost or stolen without detection.
Therefore, we recommend that the FBI amend its policy requiring all quantities of
each type of explosive material be tracked by its SABTs using handwritten logs that
detail the date, quantity in or out, purpose of the transaction, and remaining
balance; and that the FBI retain all explosives tracking records for at least 3 years.
Table 5 outlines the various methods used by the FBI offices we visited to track
explosives and the deficiencies we found with those tracking methods.
13
Table 5
Explosives Tracking Deficiencies
Boston Field Office
Denver Field Office
Handwritten log showing
The purpose of each change in the
Chicago Field Office inventory totals and changes
inventory totals was not documented
over time
The purpose of each change in the
Milwaukee Field Office inventory totals with
inventory totals was not documented
handwritten updates
New Haven Field Office
Sacramento Field Office transactions and running None
balance
CIRG – Tactical Section
inventory totals recorded
Hazardous Devices
transactions and running None
School
balance
Results of the Explosives Inventory
We conducted a physical inventory of a sample of explosives at seven of the

eight sites with an inventory of such items, comparing the inventory log balance to
the quantity on hand.4 We identified discrepancies between the quantities of
explosives on hand and the recorded inventory balance at three of the seven sites.
In total, these sites had 32 fewer explosives on hand than the balance recorded on
the inventory list. These offices could not explain the cause of the discrepancies
because they were not maintaining a record of inventory transactions. As a result,
we could not confirm whether these items were expended, or were lost or stolen
without detection. In our judgment, the discrepancies we identified are a result of
the FBI’s deficient explosives tracking and inventory policies.
Additionally, we found that the FBI does not require periodic physical
inventories of its explosive materials. In our judgment, a physical inventory of all
explosives should be conducted regularly to ensure all items are properly accounted
for on the inventory tracking documents. Consequently, we recommend that the
FBI require its offices to conduct a complete physical inventory of all explosives on
an annual basis and retain those records for at least 3 years.
4 Due to inclement weather and the location of the explosives magazine, we were unable to
complete a physical inventory of explosives at the Chicago Field Office.
14
Explosives Purchases
The FBI’s Hazardous Devices School is responsible for training and certifying
public safety bomb technicians, and as such, it purchases large quantities of
explosives. According to a Hazardous Devices School official, once it receives a
shipment of explosives, the contents of the shipping container are inventoried
against the receiving documents and the explosives are added to the inventory.
The additions are then entered into the handwritten logs and the inventory balances
are updated. We reviewed a sample of 13 purchases from the Hazardous Devices
School’s explosives inventory that were received between December 2018 and
March 2019. Based on our review, we did not identify any concerns related to the
Hazardous Devices School’s explosives purchases.
Controls over Firearm and Ammunition Evidence
The FBI maintained firearms and ammunition seized as evidence at 6 of the

15 sites included in our audit. We found that the FBI has strong physical controls
over its firearms and ammunition evidence. During our physical inventory of
firearms and ammunition evidence, we were able to locate all items in our sample
and trace a sample of items back to SENTINEL, the FBI’s evidence tracking system.
However, we identified concerns related to the disposal of firearm evidence.
Physical Security of Firearm and Ammunition Evidence
We determined that the FBI has strong physical controls over firearm and
ammunition evidence. The FBI stores its firearm and ammunition evidence in a
storage configuration, known as an Evidence Control Room (ECR), which is similar
at each location. FBI policy requires each ECR to be equipped with an electronic
keypad, combination lock, and an alarm. Access to the ECR must be limited to
designated Evidence Control Technicians, and entries must be recorded on an
access log. At all six ECRs we visited, we found that access to the ECR requires a
keycard, the combination numbers, and an alarm deactivation code. We also found
that access was limited to designated Evidence Control Technicians and all six sites
maintained access logs for recording entries into the ECR. In addition, each site
had ways to temporarily store evidence outside of the ECR when the evidence
custodian was unavailable, including lockers or a one-way chute located in the wall
of the ECR.
Accuracy of the FBI’s Firearm and Ammunition Evidence Inventory
The FBI provided us with inventory lists from SENTINEL of firearm and
ammunition evidence stored in the ECRs at the six sites we visited. In accordance
with FBI policy, the chain-of-custody information and a complete description,
including make, model, caliber, and serial number, for all firearm and ammunition
evidence must be entered into SENTINEL.
To verify the accuracy of the FBI’s firearm and ammunition evidence

inventory, we selected an evidence sample consisting of 143 items of firearms and
ammunition evidence from the inventory lists provided by the FBI to ensure they
15
were properly accounted for in SENTINEL. In addition, we selected 27 items of
firearm and ammunition evidence located in the FBI’s ECRs and attempted to trace
those items back to the inventory lists to ensure that the evidence inventory
records were complete and accurate. During our physical inventory, we located all
143 items of firearm and ammunition evidence in our sample and we traced all 27
items of firearms and ammunition evidence back to the inventory lists.
Disposal of Firearm Evidence
We evaluated controls over the FBI’s firearm evidence disposal process and
identified concerns related to firearm evidence sent to the Firearms/Toolmarks Unit
(FTU) for destruction. The FBI’s evidence management policy states that the FTU is
responsible for the destruction of all abandoned firearm evidence. This policy also
requires the firearm evidence disposal date in SENTINEL to reflect the date that the
firearm permanently leaves the ECR. Accordingly, Evidence Control Technicians in
the field ship firearms evidence to the FTU for destruction and mark the item as
destroyed in SENTINEL using the date it was shipped, rather than the date it was
destroyed. We recommend that the FBI amend its policy to require Evidence
Control Technicians to obtain and upload a notification of destruction from the FTU
prior to marking the firearm evidence as disposed in SENTINEL, and require the
firearm evidence disposal date in SENTINEL to reflect the date the firearm is
destroyed.
According to an FTU official, once the FTU receives abandoned firearms

evidence slated for disposal, including legal documentation supporting the disposal,
the firearm is entered into its electronic tracking system and assigned a barcode.
The firearm is stored in a large box in the FTU's secure destruction room. Once
that box is filled, two FTU employees scan the barcode of each firearm and place
the firearm in another container, which is sealed with metal security straps. The
FTU then sends an electronic request to the FBI’s Asset Management Unit
requesting approval for the destruction of the firearms and includes a spreadsheet
listing every firearm to be destroyed. The approval for destruction request
identifies the destruction date and who will transport the firearms, and states that
the FTU will maintain control of all firearms until they are melted down and
destroyed. Upon approval, the sealed containers are escorted to the destruction
facility and the destruction is witnessed by the FTU official assigned to escort the
sealed containers to the destruction facility. Once the firearms are destroyed, the
FTU sends a notification to the Asset Management Unit.
We determined that the FTU uses a separate inventory system, not

SENTINEL, to track the firearm evidence it receives. As a result, the FTU is
unaware of when firearms evidence is shipped to the FTU for disposal. This is
particularly concerning, because we found two of the ECRs we visited were not
confirming the delivery of firearm evidence shipped to the FTU for destruction,
which creates a temporary gap in the chain of custody when firearms marked as
destroyed could be lost or stolen without detection, particularly during shipping. At
the remaining four ECRs we visited, the Evidence Control Technicians uploaded
proof of delivery into SENTINEL when firearm evidence was shipped to the FTU for
16
destruction, which we view as a best practice that the FBI should implement
agency-wide. Therefore, we recommend that the FBI require proof of delivery to be
maintained in SENTINEL for firearms evidence shipped to the FTU for disposal.
17
CONCLUSION AND RECOMMENDATIONS
The FBI has strong physical controls over its weapons, munitions, and
explosives. However, the FBI needs to ensure all firearms have a designated
property custodian, and should improve its controls over tracking and accountability
of its ammunition, less lethal munitions, diversionary devices, and explosives
inventories. The FBI also needs to improve controls over firearm evidence slated
for destruction. Without sufficient controls over its sensitive property, the FBI
cannot be assured that its inventories of weapons, munitions, and explosives are
adequately safeguarded. Most significantly, the deficiencies we identified increase
the risk that the FBI’s weapons, munitions, and explosives can be lost, misplaced,
or stolen without detection. As a result, we make 13 recommendations to improve
the FBI’s controls over weapons, munitions, and explosives.
We recommend that the FBI:
1. Ensure all firearms in its custody are properly entered into the appropriate
property management system.
2. Ensure all firearms in its inventory have a designated property custodian, in

accordance with policy.
3. Ensures that complete documentation of lost and stolen FBI firearms is

maintained, including all pertinent information such as the firearm make,
model, and serial number.
4. Ensure that the status of all lost or stolen firearms that are subsequently
recovered is accurately reflected in AMS.
5. Amend its policy for tracking ammunition to require that all rounds of each
type of ammunition be tracked using handwritten logs that detail the date,
caliber, quantity in or out, purpose of the ammunition transaction, and
remaining balance; and require all ammunition tracking logs to be retained
for at least 3 years.
6. Revise its current policy to require its offices to conduct a complete inventory
of all ammunition on hand on an annual basis to ensure all recorded
ammunition inventory balances are accurate, and to retain those records for
at least 3 years.
7. Establish policy requiring that less lethal munitions and diversionary devices
must be stored in a secure area, with access limited to designated personnel.
8. Establish policy for tracking less lethal munitions and diversionary devices
that requires all quantities of each type of less lethal munition and
diversionary device to be tracked using handwritten logs that detail the date,
quantity in or out, purpose of the transaction, and remaining balance; and
require all less lethal munition and diversionary device tracking logs to be
retained for at least 3 years.
18
9. Require its offices to conduct a complete physical inventory of all less lethal
munitions and diversionary devices on an annual basis and retain those
records for at least 3 years.
10. Amend its policy requiring all quantities of each type of explosive material be
tracked by its SABTs using handwritten logs that detail the date, quantity in
or out, purpose of the transaction, and remaining balance; and retain all
explosives tracking records for at least 3 years.
11. Require its offices to conduct a complete physical inventory of all explosives
on an annual basis and retain those records for at least 3 years.
12. Amend its policy to require Evidence Control Technicians to obtain and
upload a notification of destruction from the FTU prior to marking the firearm
evidence as disposed in SENTINEL, and require the firearm evidence disposal
date in SENTINEL to reflect the date the firearm is destroyed.
13. Require proof of delivery to be maintained in SENTINEL for firearms evidence

shipped to the FTU for disposal.
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APPENDIX 1
OBJECTIVES, SCOPE, AND METHODOLOGY
Objectives
The objectives of the audit were to evaluate: (1) the FBI’s controls over
weapons, munitions, and explosives; (2) the FBI’s compliance with policies
governing weapons, munitions, and explosives; and (3) the accuracy of the FBI’s
weapons, munitions, and explosives inventories.
Scope and Methodology
Our audit covers the FBI’s inventories of firearms, ammunition, less lethal
munitions, diversionary devices, and explosives; and included firearms and
ammunition seized as evidence, firearm purchases, and FBI-issued firearms
reported lost or stolen from September 2015 through November 2019. To
accomplish our objectives, we interviewed personnel responsible for the FBI’s
inventory of firearms, ammunition, less lethal munitions, diversionary devices and
explosives at 15 FBI sites throughout the United States, as well as officials at the
FBI’s Headquarters. This included officials from the Finance, Inspection, Training,
and Laboratory Divisions, and Critical Incident Response Group. We also evaluated
the FBI’s policies governing weapons, munitions, and explosives. Our primary
references were the FBI’s Firearms Policy Guide (0888PG), Personal Property
Management Policy Guide (0948PG), DSU Principal Firearms Instructor
Administrative Reference, Hazardous Devices Operations Center Policy
Guide (0233PG), and the Field Evidence Management Policy Guide (0780PG).
Additionally, we examined FBI Form FD-281, Receipt for Government Property;
Form FD-500, Report of Lost or Stolen Property; and Form FD-519, Requirements
and Certification for Cannibalization and Destruction of Equipment.
We conducted site work at 15 FBI office locations. We judgmentally selected

these sites in order to examine a broad range of FBI offices and functions, including
large division field offices; smaller resident agencies; the Firearms Training Unit;
the Defensive Systems Unit; the Critical Incident Response Group’s Tactical
Section; the Hazardous Devices School; and the Laboratory Division’s
Firearms/Toolmarks Unit.
The purpose of our site work was to assess the FBI’s compliance with policies
regarding its weapons, munitions, and explosives, as well as the effectiveness of
those policies, and to determine if the FBI’s weapons, munitions, and explosives
inventories were accurate. We also wanted to determine if the FBI’s controls over
weapons, munitions, and explosives varied among different locations. We
interviewed officials at each location, including supervisors, primary firearms
instructors, special agent bomb technicians, and evidence control technicians. We
observed the physical security of the sites’ weapons, munitions, and explosives
inventories. We also reviewed firearm records from the Asset Management System
20
(AMS); and tracking documentation for ammunition, less lethal munitions,
diversionary devices, and explosives.
We conducted a physical inventory of FBI-owned weapons, munitions, and

explosives. This included verifying the existence of a sample of firearms at all of
the sites, which were selected from AMS. We also selected a sample of firearms
while on-site and traced those items back to AMS, in order to determine if the
inventory records were complete. We then analyzed select data fields in AMS in
order to assess the accuracy of those fields. In addition, we conducted physical
inventories of ammunition, less lethal munitions, diversionary devices, and
explosives on-hand to determine if all of the items were properly accounted for
using inventory tracking documentation. Similarly, we conducted a physical
inventory of firearm and ammunition evidence. This included verifying the
existence of a sample of firearm and ammunition evidence from SENTINEL at each
location. We also selected a sample of firearm and ammunition evidence while on-
site and traced those items back to the inventory list to determine if the SENTINEL
records were complete.
We reviewed documentation related to firearms and explosives purchases to

ensure that acquisitions were properly recorded. Finally, we reviewed
documentation related to firearms that were reported as lost or stolen during the
scope of our audit to determine whether the FBI took appropriate action.
Statement on Compliance with Generally Accepted Government Auditing Standards
We conducted this performance audit in accordance with generally accepted

government auditing standards (GAGAS). Those standards require that we plan
and perform the audit to obtain sufficient, appropriate evidence to provide a
reasonable basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.
Internal Controls
In this audit, we performed testing of internal controls significant within the

context of our audit objectives. We did not evaluate the internal controls of the FBI
to provide assurance on its internal control structure as a whole. FBI’s
management is responsible for the establishment and maintenance of internal
controls in accordance with OMB Circular A-123. Because we do not express an
opinion on the FBI’s internal control structure as a whole, we offer this statement
solely for the information and use of the FBI.5
5 This restriction is not intended to limit the distribution of this report, which is a matter of
public record.
21
In planning and performing our audit, we identified the following internal
control components and underlying principles as significant to the audit objectives:
Internal Control Components & Principles Significant to the Audit Objectives

Control Environment Principles
The oversight body should oversee the entity’s internal control system.
Management should establish an organizational structure, assign responsibility, and delegate
authority to achieve the entity’s objectives.
Control Activity Principles
Management should design control activities to achieve objectives and respond to risks.
Management should design the entity’s information system and related control activities to
achieve objectives and respond to risks.
Management should implement control activities through policies.
Information & Communication Principles
Management should internally communicate the necessary quality information to achieve the
entity’s objectives.
Monitoring Principles
Management should establish and operate monitoring activities to monitor the internal control
system and evaluate the results.
Management should remediate identified internal control deficiencies on a timely basis.
We assessed the design, implementation, and operating effectiveness of

these internal controls and identified deficiencies that we believe could affect the
FBI’s ability to effectively and efficiently operate, and to ensure compliance with
laws and regulations. However, because our review was limited to internal control
components and underlying principles determined to be significant to the audit
objectives, it may not have disclosed all deficiencies that may have existed at the
time of this audit. The internal control deficiencies we found are discussed in the
Audit Results section of this report.
Sample-based Testing
To accomplish our audit objectives, we performed sample-based testing for

our evaluation of the accuracy and completeness of the FBI’s inventories of
firearms, ammunition, less lethal munitions, diversionary devices, explosives, and
firearm and ammunition evidence. In this effort, we employed a judgmental
sampling design to obtain broad exposure to numerous facets of the areas we
reviewed. This non-statistical sample design did not allow projection of the test
results to the universe from which the samples were selected.
Computer-Processed Data
During our audit, we obtained inventory information from the FBI’s Asset
Management System (AMS), and SENTINEL. We did not test the reliability of those
systems as a whole, therefore any findings identified involving information from
those systems were verified with documentation from other sources.
We assessed the reliability of the inventory data received from AMS and
SENTINEL through our physical inventories of FBI-issued firearms and firearm and
22
ammunition evidence. We compared the data obtained through our physical
inspection of these items against the information recorded in AMS and SENTINEL to
ensure it was complete and accurate. We brought any identified discrepancies to
the attention of the FBI, and worked with FBI employees to correct the
discrepancies. As a result of these efforts, we determined that the AMS and
SENTINEL data was sufficiently reliable for the purposes of this report.
23
APPENDIX 2
THE FBI’S RESPONSE TO THE DRAFT AUDIT REPORT
24
25
26
27
28
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APPENDIX 3
OFFICE OF THE INSPECTOR GENERAL

ANALYSIS AND SUMMARY OF ACTIONS
NECESSARY TO CLOSE THE REPORT
The OIG provided a draft of this audit report to the FBI. The FBI’s response
is incorporated in Appendix 2 of this final report. In response to our audit report,
the FBI concurred with our recommendations and discussed the actions it will
implement in response to our findings. As a result, the status of the audit report is
resolved. The following provides the OIG analysis of the response and summary of
actions necessary to close the report.
Recommendations for the FBI:
1. Ensure all firearms in its custody are properly entered into the
appropriate property management system.
Resolved. The FBI concurred with our recommendation. The FBI stated in
its response that it will continue to ensure that all firearms are properly
entered into the Asset Management System in accordance with the FBI’s
Personal Property Management Policy Guide.
This recommendation can be closed when we receive documentation

supporting that the FBI has identified the rightful owner of the two firearms
of unknown origin found in the Madison Resident Agency and taken
appropriate action.
2. Ensure all firearms in its inventory have a designated property

custodian, in accordance with policy.
Resolved. The FBI concurred with our recommendation. In its response, the
FBI stated that the Defensive Systems Unit has amended all asset records to
reflect the required custodian. Additionally, the Asset Management Unit has
submitted a request to program an addition to the AMS data entry process
that requires all weapons to have an assigned property custodian before the
record can be saved. Further, the FBI will revise the Principal Firearms
Instructor Administrative Reference (PFIAR) to update policies and protocols
incorporating OIG observations, and communicate these points during the
annual PFI conference in April 2020. Finally, the FBI stated that it would
establish collaborative working groups to further identify firearm-related
issues and resolutions to be adopted throughout the FBI.

supporting that the FBI has reprogrammed the AMS data entry process
requiring all weapons to have an assigned property custodian before the
record can be saved and the PFIAR has been updated to incorporate OIG
observations.
30
3. Ensures that complete documentation of lost and stolen FBI firearms
is maintained, including all pertinent information such as the firearm
make, model, and serial number.
its response that it will update the Firearms Policy Guide and the PFIAR to
reflect current standard operating procedures and guidelines for lost or stolen
weapons.

supporting that the FBI has updated the Firearms Policy Guide and PFIAR
guidelines for lost or stolen weapons.
4. Ensure that the status of all lost or stolen firearms that are
subsequently recovered is accurately reflected in AMS.
its response that it will update the Firearms Policy Guide and the PFIAR to
reflect current standard operating procedures and guidelines for recovered
lost or stolen weapons.

supporting that the FBI has updated the Firearms Policy Guide and PFIAR
guidelines for recovered lost or stolen weapons.
5. Amend its policy for tracking ammunition to require that all rounds of
each type of ammunition be tracked using handwritten logs that
detail the date, caliber, quantity in or out, purpose of the ammunition
transaction, and remaining balance; and require all ammunition
tracking logs to be retained for at least 3 years.
FBI stated that the Firearms Policy Guide will be updated to require
ammunition inventories to be maintained through the use of handwritten
inventory sheets showing the date of transaction, ammunition name, caliber,
transaction in or out, and purpose of the transaction. These sheets will be
maintained for 3 years.

supporting that the Firearms Policy Guide has been updated to require all
ammunition inventories to be maintained using handwritten logs showing the
transaction date, caliber, quantity in or out, purpose of the ammunition
transaction, and remaining balance on hand; and for these logs to be
retained for 3 years.
31
6. Revise its current policy to require its offices to conduct a complete
inventory of all ammunition on hand on an annual basis to ensure all
recorded ammunition inventory balances are accurate, and to retain
those records for at least 3 years.
its response that it will update the Firearms Policy Guide to require PFIs, on
an annual basis, to submit an inventory of all ammunition on hand, by caliber
and type, to the Firearms Training Unit, and maintain the inventory for
3 years.

supporting that the FBI has updated the Firearms Policy Guide requiring PFIs
to conduct an annual physical inventory of all ammunition on hand to ensure
the inventory balances on the handwritten tracking logs are accurate.
7. Establish policy requiring that less lethal munitions and diversionary

devices must be stored in a secure area, with access limited to
designated personnel.
FBI stated that the Tactical Section is currently consolidating and updating
three policies into one Tactical Policy Guide that will include storage
requirements for less lethal munitions and diversionary devices, and limit
access to the secure storage area to designated personnel.

supporting that the Tactical Policy Guide has been implemented, establishing
secure storage requirements for less lethal munitions and diversionary
devices, and limiting access to the storage area to designated personnel.
8. Establish policy for tracking less lethal munitions and diversionary

devices that requires all quantities of each type of less lethal
munition and diversionary device to be tracked using handwritten
logs that detail the date, quantity in or out, purpose of the
transaction, and remaining balance; and require all less lethal
munition and diversionary device tracking logs to be retained for at
least 3 years.
its response that the Tactical Section is currently consolidating and updating
three policies into one Tactical Policy Guide that will establish guidance on
tracking less lethal munitions and diversionary devices using handwritten
logs that include the date, quantity in or out, purpose of the transaction, and
remaining balance. The policy guide will also require the tracking logs to be

supporting that the Tactical Policy Guide has been implemented, establishing
32
the requirement to track less lethal munitions and diversionary devices using
handwritten logs that detail the date, quantity in or out, purpose of the
transaction, and remaining balance on hand; and mandate that the logs be
9. Require its offices to conduct a complete physical inventory of all less

lethal munitions and diversionary devices on an annual basis and
retain those records for at least 3 years.
FBI stated that the Tactical Section is currently consolidating and updating
three policies into one Tactical Policy Guide that will require offices to conduct
a complete annual physical inventory of all less lethal munitions and
diversionary devices and retain the records for at least 3 years.

supporting that the Tactical Policy Guide has been implemented, requiring
offices to conduct a complete annual physical inventory of all less lethal
munitions and diversionary devices and retain the records for at least
3 years.
10. Amend its policy requiring all quantities of each type of explosive
material be tracked by its SABTs using handwritten logs that detail
the date, quantity in or out, purpose of the transaction, and
remaining balance; and retain all explosives tracking records for at
least 3 years.
its response that the Counter-IED Section is currently revising the Hazardous
Devices Operations Center Policy Guide. While the Policy Guide is being
finalized and approved, the Counter-IED Section will draft interim policy on
the responsibilities and requirements associated with explosives storage and
accountability to ensure that FBI personnel adhere to established Standard
Operating Procedures to prevent the loss or theft of explosives without
detection. The explosives inventory procedures used by the Hazardous
Devices School will be implemented through this interim policy. To maintain
explosives inventory records, the Counter-IED Section will establish a control
file in Sentinel, the FBI’s central recordkeeping system, for field office
reporting of bi-annual explosives inventories and transaction logs, which will
be maintained for at least 3 years.

supporting that the interim policy has been established, and incorporated
into the revised Hazardous Devices Operations Center Policy Guide, requiring
all quantities of each type of explosive material be tracked using handwritten
logs that detail the date, quantity in or out, purpose of the transaction, and
remaining balance; and that those explosives tracking records are retained
for at least 3 years.
33
11. Require its offices to conduct a complete physical inventory of all
explosives on an annual basis and retain those records for at least
3 years.
its response that the interim policy will require FBI personnel to adhere to a
standardized explosives tracking and inventory process and log all movement
of explosives in and out of approved storage locations. Specifically, the FBI
field offices will be required to conduct a complete physical inventory of all
explosives on a bi-annual basis and document inventories with transaction
logs to the appropriate Sentinel files for review by the Counter-IED Section.
These records will be maintained for at least 3 years.

supporting that the interim policy has been established, and incorporated
into the revised Hazardous Devices Operations Center Policy Guide, requiring
field offices to conduct a complete bi-annual physical inventory of all
explosives on hand and retain those records for at least 3 years.
12. Amend its policy to require Evidence Control Technicians to obtain

and upload a notification of destruction from the FTU prior to
marking the firearm evidence as disposed in SENTINEL, and require
the firearm evidence disposal date in SENTINEL to reflect the date
the firearm is destroyed.
FBI explained that the Laboratory Division has always issued an Electronic
Communication (EC) in Sentinel when the final destruction of submitted
firearms occurs. This EC will be modified so that all field office Evidence
Control Technicians (ECTs), who have submitted firearms for destruction,
receive the EC via Sentinel. The FBI also stated that the Laboratory Division
proposes that the Field Evidence Management Policy Guide be changed to
require the following actions:
(a) Require the ECT to disposition weapons in Sentinel by using the
date of receipt of the weapon by the Laboratory Division. The
date will be obtained from the documentation of delivery
provided by the trackable carrier, which confirms the weapon
has been received by the Laboratory Division.
(b) Require the ECTs, upon receipt of the latest Laboratory
Division’s firearms destruction EC via Sentinel, to upload that EC
into their case file to document the final destruction of the
related firearm.

supporting that: (1) the EC in Sentinel communicates the final destruction
date to the appropriate ECT; and (2) the Field Evidence Management Policy
Guide has been revised to require the firearm disposal date to reflect the
34
date of delivery to the Laboratory Division, and the final disposition EC to be
included in the case file.
13. Require proof of delivery to be maintained in SENTINEL for firearms
evidence shipped to the FTU for disposal.
FBI stated that the Laboratory Division proposes changes to the Field
Evidence Management Policy Guide to require the following actions when
firearms are shipped to the Laboratory Division for destruction:
(a) The respective ECT prepares the firearm for shipment to the
Laboratory Division.
(b) The ECT ships the weapon to the Laboratory Division through a
trackable carrier.
(c) The ECT serializes the return receipt from the trackable carrier
(e.g., Registered Mail or FedEx signature page) into Sentinel
and maintains a hard copy of the return receipt.
(d) ECT dispositions the weapon in Sentinel as disposed, using the
date on the receipt from the trackable carrier which confirms the
weapon has been received by the Laboratory Division for
destruction.

supporting that the Field Evidence Management Policy Guide has been
revised to require the disposal procedures described in the FBI’s response.
35
The Department of Justice Office of the Inspector General (DOJ OIG) is a
statutorily created independent entity whose mission is to detect and deter
waste, fraud, abuse, and misconduct in the Department of Justice, and to
promote economy and efficiency in the Department’s operations.
To report allegations of waste, fraud, abuse, or misconduct regarding DOJ

programs, employees, contractors, grants, or contracts please visit or call the
DOJ OIG Hotline at oig.justice.gov/hotline or (800) 869-4499.
U.S. DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL

950 Pennsylvania Avenue, NW
Washington, DC 20530-0001
Website Twitter YouTube

oig.justice.gov @JusticeOIG JusticeOIG
Also at Oversight.gov

DOJ IG - Audit of The FBI's Controls Over Weapons, Munitions, and Explosives

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Office of the Inspector General

U.S. Department of Justice

Audit of the Federal Bureau of

Audit Division 20-041 March 2020

Objectives Audit Results

Controls over Explosives – The FBI maintained

OIG Audit Approach ....................................................................... 1

Controls over Firearms ................................................................... 3

Physical Security of Firearms ................................................... 3

Accuracy of the FBI’s Asset Management System .......................... 3

Firearm Purchases ................................................................ 4

Firearm Disposal .................................................................. 5

Lost and Stolen Firearms ........................................................ 5

Controls over Ammunition ............................................................... 8

Physical Security of Ammunition ............................................... 8

Ammunition Tracking ............................................................. 9

Results of the Ammunition Inventory ....................................... 10

Controls over Less Lethal Munitions and Diversionary Devices ................ 10

Physical Security of Less Lethal Munitions and Diversionary Devices .. 11

Tracking Less Lethal Munitions and Diversionary Devices .............. 11

Results of the Less Lethal Munitions and Diversionary Devices

Controls over Explosives ............................................................... 12

Physical Security of Explosives ............................................... 13

Tracking Explosives ............................................................. 13

Results of the Explosives Inventory ......................................... 14

Controls over Firearm and Ammunition Evidence................................. 15

Physical Security of Firearm and Ammunition Evidence ................. 15

Accuracy of the FBI’s Firearm and Ammunition Evidence Inventory . 15

Disposal of Firearm Evidence ................................................. 16

CONCLUSION AND RECOMMENDATIONS ................................................... 18

APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY.............................. 20

APPENDIX 2: THE FBI’S RESPONSE TO THE DRAFT AUDIT REPORT ................. 24

APPENDIX 3: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY

The Federal Bureau of Investigation (FBI) currently employs over 13,000

As a result of its criminal enforcement activity, FBI personnel may seize

OIG Audit Approach

To accomplish our objectives, we interviewed FBI personnel, including

1 See Appendix 1 for a list of FBI policies we reviewed.

Controls over Firearms

The FBI tracks its firearms inventory using an automated property

Physical Security of Firearms

Accuracy of the FBI’s Asset Management System

As of August 2019, the FBI reported 57,812 firearms in its inventory. We

The FBI’s Defensive Systems Unit (DSU) is responsible for purchasing,

We identified concerns related to the record keeping of disposed FBI-issued

Lost and Stolen Firearms

We reviewed the FBI’s records to determine whether it took disciplinary

To ensure the accuracy of the FBI’s tracking information, we reviewed AMS

Controls over Ammunition

The FBI maintained duty ammunition at 14 of the 15 sites we reviewed. We

Physical Security of Ammunition

Strong controls over ammunition require an inventory management system

Results of the Ammunition Inventory

In order to assess the accuracy of the FBI’s ammunition inventories, we

Controls over Less Lethal Munitions and Diversionary Devices

Physical Security of Less Lethal Munitions and Diversionary Devices

Tracking Less Lethal Munitions and Diversionary Devices

Results of the Less Lethal Munitions and Diversionary Devices Inventory

We conducted a physical inventory of less lethal munitions and diversionary

Controls over Explosives

The FBI maintained explosives at 8 of the 15 sites we reviewed. We found

Strong controls over explosives require an inventory management system

Results of the Explosives Inventory